Changes to the Hazard Communication Standard

Notice: If you were assigned the Hazard Communication Course, read this

The Globally Harmonized System of Chemical Classification (GHS)In March of 2012, the Occupational Safety and Health Administration (OSHA) updated the Hazard Communication Standard CFR29 1910.1200 (HazCom) to align with the Globally Harmonized System of Chemical Classification (GHS). Over the next three years, chemical manufacturers, distributors, employers and consumers will see changes in the way that chemical hazards are communicated on labels and safety documentation.

The intent of the new legislation is to make it easier for workers to understand chemical hazards, especially workers who may not speak or read English well, reduce confusion in the workplace, make safety training easier, and result in safer handling and use of chemicals. The new format will provide workers with quicker and more efficient access to information on the labels and safety data sheets. The changes will also save money for American businesses with productivity improvements projected because of fewer safety data sheet and label updates and simpler new hazard communication training. The new labeling system should also reduce trade barriers by coordinating with systems already in use in other countries.

What this means for employees at UABSince these major changes to labeling and safety information apply to all materials that have a chemical hazard, everyone employed by the University or the University Medical System will need to take the basic Hazard Communication training HS200 before the end of the year. Many job classifications may not work directly with hazardous chemicals, but since everyday materials such as paints drain cleaners and disinfectants will be relabeled using the new system, everyone needs to know how to recognize and use the new labels and information sheets.

Major Changes

Manufacturers must now classify hazardous chemicals according to standardized international criteria.

The detailed chemical information sheets are now called Safety Data Sheets instead of Material Safety Data Sheets and the layout of the information is always organized the same way.

Pictograms will provide visual clues of the chemical hazards.

Signal words: Danger and Warning will be used to describe how dangerous the material is.

Here are the pictograms that will appear on safety data sheets and labels:

Labels will all be organized the same way with the following standard components.• The Product Identifier or material name• Supplier Identification to let users know who manufactured or distributed the material• Precautionary Statements that describe how to protect yourself from the dangers of the material• Pictograms to provide a visual clue to the hazards.• Signal Words that describe the relative hazard, just like on the safety data sheet• Hazard Statements that describe the characteristic that makes the material dangerous• Supplemental Information that may give contact information for getting additional information or contacting the manufacturer.

Safety Data Sheets will have 16 Required Elements all listed in the same order. In addition, the information in section 2 will include the same pictograms and warnings as the information on the label. Here are the required sections of the new safety data sheets.

Chemical Inventory Management System

The Department of Occupational Health and Safety is starting the implementation of a campus-wide chemical inventory system to track hazardous chemicals. The system utilizes bar codes and features a web-based interface. This will allow researchers, laboratory staff and other chemical users to track chemicals on-hand, will aid OH&S with regulatory agency reporting, and will provide emergency responders with accurate information on the chemical hazards present within an area should an incident occur.

We understand that some areas use large amounts of commercial products or may use chemicals that are mixtures that need to be inventoried. These items may not have a CAS# or they may have more than one CAS# associated with them. We have created UAB and OH&S numbers for these items to input into the CAS# field on the Chemical Inventory System. Should you find that the chemical/product you are looking for is not present on our list of created UAB and OH&S numbers please contact OH&S at 934-2487.

Most chemicals will need to be entered into the inventory, but the following types of materials will not:

OH&S staff will be meeting with departmental staff to discuss the program's use and features. To make this transition easier, OH&S will perform the initial inventory in each laboratory. We are asking that unwanted and expired chemicals be disposed and any excessive clutter be removed before the inventory takes place to make the process as safe and efficient as possible. Here are some guidelines for lab staff.

Preparing for the initial chemical inventory

OH&S staff will be conducting the initial chemical inventory in your lab. In order to make this process as safe and efficient as possible, we are asking that laboratory personnel make some basic preparations.Please:

Discard all chemicals that are no longer useful to your research, expired (or more than 5 years old), or degraded – look for crystals, phase separation, container damage. Properly pack these chemicals and complete a Hazardous Waste Manifest to have them picked up.

Ensure that any spills or other contamination are cleaned up properly – pay particular attention to cabinets and refrigerators.

Check that chemicals in freezers are not frozen together or stuck to the sides or shelves.

Ensure that materials to be inventoried are in their proper storage location.

Ensure that chemicals have legible and appropriate labels – the ChemWatch system can be used to print a GHS compliant label if the original container label is damaged or inadequate. Structures and abbreviations of chemical names are not appropriate as the sole indicator of a chemical's identity.

Place signs or communicate directly with the personnel who are conducting the inventory if there are sensitive or potentially hazardous procedures in progress.

Ensure that there is a clean counter space for sorting and marking of chemical containers.

Set aside a location for staging of containers that may need to be relabeled or packed as waste.

Make sure aisles are clear and that there is good access to all chemical storage locations.

Proper storage of chemicals

Chemicals need to be stored according to hazard class to prevent unwanted reactions in case of fire or other emergency. Flammable liquids in quantities greater than 10 gallons must be stored in flammable storage cabinets. Acids and bases must be stored separately and oxidizers need to be stored away from organic materials that could react to cause a fire. Here are some additional links to guidelines for proper chemical storage:Making Sense Out of Chemical StorageEPA Chemical Segregation Chart

At the time of inventory:• Tell the inventory staff if you would like specifically labeled sub-locations for your materials – OH&S only requires the building and room, but we can list by shelves, cabinets – etc.• Chemical containers will be barcoded and returned to their original location after being entered into the Chemical Management System.• Containers that are damaged, unlabeled, or expired will not be entered and will be moved to the designated location for disposal.• Chemicals in locations that show signs of gross leakage or contamination will not be entered and the materials will be marked for disposal as waste.• Most chemicals in their original containers will be inventoried. Buffers, dilutions and cleaning products will not be included in the inventory.• You will be given a supply of preprinted barcode labels to use for chemicals purchased in the future. When you need additional labels contact OH&S at 934-2487.

During the initial inventory additional bar code labels will be distributed so that new materials can be added. For additional labels, please contact OH&S at 934-2487.